SBA Loan Closing Checklist

SBA LOAN CLOSING CHECKLIST

Comprehensive Pre-Closing, Closing, and Post-Closing Guide for SBA 7(a) and 504 Loans

Borrower Name: [________________________________]
Lender Name: [________________________________]
SBA Loan Number: [________________________________]
Loan Program: ☐ 7(a) Standard ☐ 7(a) Small ☐ SBA Express ☐ 504/CDC ☐ Other: [____]
Approved Loan Amount: $[________________________________]
SBA Authorization Date: [__/__/____]
Target Closing Date: [__/__/____]
Closing Attorney / Agent: [________________________________]
Prepared By: [________________________________]
Date Prepared: [__/__/____]

PHASE 1: PRE-CLOSING CONDITIONS AND PREPARATION

1.1 SBA Authorization Review

☐ SBA Authorization (Loan Authorization and Agreement) received and reviewed
☐ All conditions in the SBA Authorization identified and tracked
☐ Authorization conditions categorized as:

• ☐ Pre-disbursement conditions (must be satisfied before any funding)

• ☐ Post-closing conditions (must be satisfied within specified time after closing)
  ☐ SBA Authorization expiration date confirmed: [__/__/____]

• Note: Standard SBA Authorizations typically expire 6 months from issuance; extensions may be requested.
  ☐ Any SBA Authorization amendments or modifications obtained and reviewed
  ☐ Loan amount, interest rate, maturity, and use of proceeds confirmed to match SBA Authorization

1.2 Entity and Authority Verification

☐ Borrower Entity Documents:

• ☐ Articles of Incorporation / Articles of Organization / Certificate of Formation
• ☐ Bylaws (corporation) or Operating Agreement (LLC)
• ☐ Partnership Agreement (partnership)
• ☐ Amendments to organizational documents (all)
• ☐ Certificate of Good Standing — state of organization (dated within 30 days of closing)
• ☐ Certificate of Good Standing / Certificate of Authority — state(s) where business operates (if different)
• ☐ EIN verification (IRS Form CP 575 or IRS Letter 147C)

☐ Borrower Resolutions / Consents:

• ☐ Corporate resolution (board of directors) authorizing the loan, execution of loan documents, and pledge of collateral
• ☐ LLC member/manager consent or resolution authorizing the loan
• ☐ Partnership consent or resolution authorizing the loan
• ☐ Secretary's / Manager's certificate certifying the resolution and identifying authorized signatories

☐ Guarantor Entity Documents (if Guarantor is an entity):

• ☐ Organizational documents
• ☐ Good standing certificate
• ☐ Resolution authorizing the guaranty

☐ Incumbency Certificate — Identifying officers/managers authorized to sign on behalf of Borrower

1.3 Title and Lien Search (Real Property Collateral)

☐ Preliminary title report / title commitment received and reviewed
☐ All exceptions to title identified and evaluated:

• ☐ Acceptable exceptions listed on Schedule B

• ☐ Unacceptable exceptions to be cleared before closing
  ☐ Lender's title insurance policy commitment:

• ☐ Issuing company: [________________________________]

• ☐ Policy amount: $[________________________________]

• ☐ Policy type: ☐ ALTA Loan Policy ☐ Other: [____]
  ☐ Required title endorsements identified:

• ☐ ALTA 3.1 (Zoning — Completed Structure)

• ☐ ALTA 4 (Condominium)
• ☐ ALTA 5 (Planned Unit Development)
• ☐ ALTA 6 (Variable Rate Mortgage)
• ☐ ALTA 8.1 (Environmental Protection Lien)
• ☐ ALTA 9 (Restrictions, Encroachments, Minerals)
• ☐ ALTA 17 (Access and Entry)
• ☐ ALTA 28 (Easement — Damage or Enforced Removal)
• ☐ Other: [________________________________]
  ☐ Legal description confirmed and matches deed, mortgage/deed of trust, and title commitment
  ☐ Survey reviewed and matches legal description (no encroachments or boundary issues)

1.4 UCC and Personal Property Lien Searches

☐ UCC search — Secretary of State (Borrower's state of organization): [________________________________]

• Date of search: [__/__/____]
• Results: ☐ Clear ☐ Prior filings identified (list below)
  ☐ UCC search — Secretary of State (state where collateral is located, if different)
  ☐ UCC search — County filing office (if applicable)
  ☐ Federal tax lien search (county recorder and Secretary of State)
  ☐ State tax lien search
  ☐ Judgment lien search (county clerk and/or federal court)
  ☐ Bankruptcy search (PACER) for Borrower and all Guarantors

Prior Filings / Liens Identified:

☐ UCC-3 Termination Statements or subordination agreements obtained for all prior filings that must be cleared or subordinated

1.5 Appraisal and Environmental

☐ Appraisal (if real property collateral):

• ☐ Appraisal completed by state-certified/licensed appraiser
• ☐ Appraised value: $[________________________________]
• ☐ Appraisal date: [__/__/____] (must be within 12 months of closing)
• ☐ Appraisal complies with FIRREA and SBA requirements
• ☐ Appraisal review completed by Lender (if required)
• ☐ Loan-to-value ratio: [____]% (calculated as loan amount ÷ appraised value)

☐ Environmental Assessment:

• ☐ Phase I Environmental Site Assessment completed
• ☐ Assessment date: [__/__/____]
• ☐ Result: ☐ No recognized environmental conditions ☐ RECs identified (Phase II required)
• ☐ Phase II Environmental Assessment (if required): ☐ Completed ☐ Results satisfactory
• ☐ Environmental indemnification agreement (if applicable)

☐ Flood Determination:

• ☐ Standard Flood Hazard Determination form completed
• ☐ Property is ☐ in / ☐ not in a FEMA Special Flood Hazard Area
• ☐ Flood insurance required: ☐ Yes ☐ No
• ☐ Flood insurance obtained (if required) — Policy No.: [________________________________]

PHASE 2: LOAN DOCUMENT PREPARATION AND EXECUTION

2.1 Primary Loan Documents

☐ Promissory Note

• ☐ Principal amount matches SBA Authorization
• ☐ Interest rate matches SBA Authorization and complies with SBA maximum rate limits
• ☐ Maturity date correct
• ☐ Payment schedule matches SBA Authorization
• ☐ Prepayment provisions (including SBA subsidy recoupment fee, if applicable) included
• ☐ Default provisions and remedies included
• ☐ Late charge provision included (typically 5% of late payment amount)
• ☐ Executed by Borrower

☐ Loan Agreement

• ☐ Conditions precedent to disbursement
• ☐ Representations and warranties
• ☐ Affirmative and negative covenants
• ☐ Financial reporting requirements
• ☐ Events of default
• ☐ Use of proceeds restrictions (must match SBA Authorization)
• ☐ Executed by Borrower and Lender

☐ Security Agreement

• ☐ Collateral description matches SBA Authorization
• ☐ Covers all business assets (blanket lien) as required by SBA
• ☐ Specific collateral items identified where applicable
• ☐ After-acquired property clause included
• ☐ Executed by Borrower (and any third-party pledgors)

☐ Guaranty Agreement(s)

• ☐ Unlimited personal guaranty from each 20%+ owner (SBA standard requirement)
• ☐ SBA-approved limited guaranty (if applicable under program guidelines)
• ☐ Spousal guaranty (if required under applicable state community property law)
• ☐ Executed by each Guarantor

☐ Disbursement Authorization

• ☐ Wire transfer instructions
• ☐ Payoff instructions for debt being refinanced (if applicable)
• ☐ Escrow/holdback instructions (if applicable)
• ☐ Executed by Borrower

2.2 Real Property Security Documents (If Applicable)

☐ Mortgage / Deed of Trust

• ☐ Property description (legal description) matches title commitment and survey
• ☐ Properly identifies Borrower as Mortgagor/Trustor and Lender as Mortgagee/Beneficiary
• ☐ Loan amount and maturity date included
• ☐ Includes standard covenants (insurance, taxes, maintenance, etc.)
• ☐ Assignment of rents clause included
• ☐ Executed and notarized/acknowledged

☐ Assignment of Leases and Rents (separate document, if applicable)

• ☐ Covers all current and future leases on the property
• ☐ Executed by Borrower

☐ Environmental Indemnification Agreement

• ☐ Executed by Borrower and Guarantor(s)

☐ Fixture Filing (UCC-1 as fixture filing)

• ☐ Prepared for recording in county land records

2.3 Additional Security Documents

☐ Collateral Assignment of Life Insurance

• ☐ Insurance company: [________________________________]
• ☐ Policy number: [________________________________]
• ☐ Insured: [________________________________]
• ☐ Face amount: $[________________________________]
• ☐ Assignment form completed and submitted to insurance company
• ☐ Acknowledgment of assignment received from insurance company

☐ Pledge Agreement (if pledging securities, partnership interests, or deposit accounts)

• ☐ Identification of pledged assets
• ☐ Control agreement (for deposit accounts or securities accounts)
• ☐ Executed by pledgor

☐ Landlord's Waiver / Landlord's Consent and Estoppel (if business operates at leased premises)

• ☐ Landlord waives lien on business personal property
• ☐ Landlord acknowledges Lender's security interest
• ☐ Lender has right to access premises for collateral inspection/removal
• ☐ Executed by Landlord

☐ Subordination Agreement(s) (if applicable)

• ☐ From: [________________________________]
• ☐ Nature of subordinated obligation: [________________________________]
• ☐ Executed by subordinating creditor

☐ Inter-Creditor Agreement (if multiple lenders or SBA 504 structure)

• ☐ Executed by all creditor parties

PHASE 3: INSURANCE VERIFICATION

3.1 Required Insurance Policies

☐ Commercial General Liability Insurance

• ☐ Certificate of Insurance (COI) received
• ☐ Minimum coverage: $[________________________________] per occurrence
• ☐ Lender named as additional insured
• ☐ Policy effective dates cover closing date

☐ Property / Hazard Insurance

• ☐ Certificate of Insurance received
• ☐ Coverage amount: Replacement cost of improvements or loan amount (whichever is less)
• ☐ Lender named as loss payee (mortgagee clause)
• ☐ Policy effective dates cover closing date

☐ Business Interruption / Loss of Rents Insurance (if required)

• ☐ Certificate of Insurance received
• ☐ Coverage sufficient to cover 12 months of debt service

☐ Flood Insurance (if in FEMA Special Flood Hazard Area)

• ☐ Obtained through National Flood Insurance Program (NFIP) or private carrier
• ☐ Coverage amount: Loan amount or maximum available under NFIP (whichever is less)
• ☐ Lender named as loss payee

☐ Workers' Compensation Insurance

• ☐ Certificate of Insurance received (or exempt status confirmed)

☐ Auto Insurance (if vehicles are collateral)

• ☐ Lender named as loss payee

☐ Key Person Life Insurance

• ☐ Policy in effect with collateral assignment to Lender acknowledged by insurance company

☐ Builder's Risk Insurance (if construction loan)

• ☐ Coverage sufficient to cover loan amount
• ☐ Lender named as loss payee

☐ Professional Liability / E&O Insurance (if applicable to business type)

PHASE 4: FINANCIAL CONDITIONS AND VERIFICATIONS

4.1 Financial Condition Verification

☐ Updated financial statements received (within 90 days of closing)

• ☐ Business: P&L and Balance Sheet through [__/__/____]

• ☐ Personal: SBA Form 413 updated (for each 20%+ owner)
  ☐ No material adverse change certification signed by Borrower
  ☐ Updated accounts receivable aging
  ☐ Updated accounts payable aging
  ☐ Existing debt verified (payoff letters obtained, if refinancing)
  ☐ Tax compliance verified:

• ☐ No outstanding federal tax liens

• ☐ No outstanding state tax liens
• ☐ IRS transcripts obtained (Form 4506-C processed)

4.2 Equity Injection Verification (If Applicable)

☐ Borrower equity injection amount: $[________________________________]
☐ Source of equity injection verified:

• ☐ Bank statements confirming available funds
• ☐ Gift letter and donor verification (if gift funds)
• ☐ Sale documentation (if from sale of assets)
• ☐ Other: [________________________________]
  ☐ Equity injection deposited into Borrower's business account
  ☐ Equity injection must be made prior to or simultaneously with first disbursement of SBA loan proceeds

4.3 Standby Debt Verification (If Applicable)

☐ Standby creditor note or agreement obtained
☐ Terms comply with SBA standby requirements:

• ☐ No payments for first [____] months
• ☐ Interest rate does not exceed Lender's rate on SBA loan
• ☐ Subordinated to SBA loan on full standby
  ☐ SBA-approved standby agreement form used

PHASE 5: SBA-SPECIFIC CLOSING REQUIREMENTS

5.1 SBA Form 1050 — Settlement Sheet (Use of Proceeds Certification)

☐ SBA Form 1050 prepared and completed

• ☐ Required for all 7(a) loans over $350,000 and all PLP loans
• ☐ Documents that loan proceeds were disbursed in accordance with the SBA Authorization
• ☐ Documents that Borrower's equity injection was made prior to or simultaneously with disbursement
• ☐ Executed by both Lender and Borrower at time of initial disbursement

☐ Use of Proceeds Breakdown:

☐ Supporting documentation for each disbursement retained (joint payee checks, wire confirmations, invoices, receipts)

5.2 SBA Fee Payment

☐ SBA Guaranty Fee (upfront) calculated:

• Loan amount: $[________________________________]
• Guaranteed portion: $[________________________________]
• Fee percentage: [____]%

• Fee amount: $[________________________________]
  ☐ SBA Guaranty Fee:

• ☐ Paid by Borrower at closing

• ☐ Financed into loan proceeds
• ☐ Paid by Lender (to be reimbursed)
  ☐ SBA Guaranty Fee remitted to SBA (typically via Lender within 90 days of disbursement)

5.3 SBA Eligibility Confirmations

☐ Borrower eligibility confirmed per 13 CFR § 120.100
☐ Size standard compliance confirmed per 13 CFR Part 121
☐ Use of proceeds confirmed as eligible per SBA Authorization
☐ No SBA-prohibited activities
☐ No debarment or suspension (checked against SAM.gov)
☐ CAIVRS check completed (Credit Alert Interactive Voice Response System — confirms no federal debt delinquency)
☐ SBA disaster area certification (if applicable)

PHASE 6: CLOSING DAY PROCEDURES

6.1 Document Execution

☐ All loan documents assembled for execution
☐ Closing agent / attorney present
☐ Authorized signatories present (or proper power of attorney in place)
☐ All documents executed by all required parties
☐ Notarization / acknowledgment completed for all recorded documents
☐ Borrower received copies of all executed documents
☐ Lender received executed originals

6.2 Disbursement

☐ All conditions precedent to disbursement verified as satisfied
☐ Wire instructions confirmed with receiving institution
☐ Disbursement authorized by Lender
☐ Funds wired:

• ☐ To Borrower's account: $[________________________________]
• ☐ To payoff existing debt: $[________________________________] to [________________________________]
• ☐ To escrow/title: $[________________________________]
• ☐ To seller (acquisition): $[________________________________]
• ☐ To SBA (guaranty fee): $[________________________________]
• ☐ Other: $[________________________________]
  ☐ Wire confirmations received and filed
  ☐ SBA Form 1050 signed at time of disbursement

6.3 Closing Funds Reconciliation

PHASE 7: POST-CLOSING REQUIREMENTS

7.1 Recording and Filing (Within 5-10 Business Days After Closing)

☐ Real Property Documents Recorded:

• ☐ Mortgage / Deed of Trust recorded in [________________________________] County
• ☐ Recording date: [__/__/____]
• ☐ Recording reference: Book [____] Page [____] / Document No.: [________________________________]
• ☐ Assignment of Leases and Rents recorded (if separate document)
• ☐ Fixture filing recorded (if applicable)

☐ UCC Filings:

• ☐ UCC-1 Financing Statement filed with Secretary of State of [________________________________]
• ☐ Filing date: [__/__/____]
• ☐ Filing number: [________________________________]
• ☐ UCC-1 filed in additional states (if collateral in multiple states)
• ☐ UCC-1 filed with county recorder (if required for fixtures or as-extracted collateral)

☐ Vehicle Title Liens (if applicable):

• ☐ Lien noted on vehicle title(s) with DMV
• ☐ Vehicle(s): [________________________________]

7.2 Title Insurance

☐ Final lender's title insurance policy received
☐ Policy reviewed for accuracy:

• ☐ Insured party (Lender) correctly identified
• ☐ Policy amount matches loan amount
• ☐ Legal description correct
• ☐ Exceptions reviewed and acceptable
• ☐ All required endorsements attached
  ☐ Title policy filed in Lender's permanent loan file

7.3 Insurance Policy Verification

☐ Final insurance policies received (not just certificates) showing:

• ☐ Lender as loss payee / mortgagee
• ☐ Lender as additional insured (for liability policies)
• ☐ 30-day cancellation notice provision to Lender
  ☐ Insurance tracking system updated with policy information and renewal dates
  ☐ Life insurance collateral assignment acknowledged by insurance company (in writing)

7.4 SBA Post-Closing Submissions

☐ SBA Guaranty Fee remitted to SBA (within 90 days of first disbursement)
☐ SBA Form 1050 (executed) retained in loan file
☐ Copies of all executed closing documents retained in loan file
☐ Loan booked on Lender's system with correct terms
☐ SBA loan number entered into E-Tran / SBA systems
☐ First payment date confirmed with Borrower

7.5 Post-Closing Condition Follow-Up

Track and verify satisfaction of all post-closing conditions from the SBA Authorization:

7.6 Ongoing Monitoring Setup

☐ Payment schedule entered into servicing system
☐ Financial reporting requirements calendared
☐ Insurance renewal tracking established
☐ UCC continuation statement reminder set (file within 6 months before 5-year expiration)
☐ Property tax monitoring established
☐ Covenant compliance monitoring schedule established
☐ Annual review date set: [__/__/____]

PHASE 8: SBA 504/CDC ADDITIONAL CLOSING REQUIREMENTS

(Complete this section only for SBA 504/CDC loans.)

8.1 CDC-Specific Documents

☐ CDC Loan Authorization and Debenture Guarantee
☐ CDC Note (second lien)
☐ CDC Deed of Trust / Mortgage (second position)
☐ CDC Development Agreement
☐ SBA Debenture
☐ Interim lender documentation (if bridge loan used before debenture funding)

8.2 504 Debenture Funding

☐ Debenture funding date confirmed: [__/__/____]

• Note: SBA 504 debentures are funded on a monthly schedule; check SBA's 504 Debenture Funding Schedule.
  ☐ Project completion certification (for construction projects)
  ☐ Interim financing to be taken out by debenture proceeds
  ☐ CDC review and submission to SBA

CERTIFICATION

I certify that the items listed above have been reviewed and completed (or are being tracked for completion) in connection with the closing of the above-referenced SBA loan. Any incomplete items are noted and being actively monitored.

Closing Attorney / Agent: [________________________________]
Signature: ______________________________
Date: [__/__/____]

Lender Representative: [________________________________]
Signature: ______________________________
Date: [__/__/____]

SOURCES AND REFERENCES

• SBA 7(a) Loan Program: https://www.sba.gov/funding-programs/loans/7a-loans
• SBA Loan Closing Procedures: https://www.sba.gov/about-sba/sba-locations/loan-guaranty-centers/loan-guaranty-processing-center-citrus-heights-ca-hazard-ky/loan-closing
• SBA Form 1050 (Settlement Sheet): https://www.sba.gov/document/sba-form-1050-settlement-sheet-use-proceeds-certification
• SBA SOP 50 10 (Lender and Development Company Loan Programs): https://www.sba.gov/document/sop-50-10
• SBA SOP 50 57 (7(a) Loan Servicing): https://www.sba.gov/document/sop-50-57
• SBA 504 Debenture Funding Schedule: https://www.sba.gov/document/information-notice-5000-860285-504-debenture-funding-schedule-calendar-year-2025
• 13 CFR Part 120 (SBA Business Loans): https://www.law.cornell.edu/cfr/text/13/part-120
• UCC Article 9 (Secured Transactions): Uniform Commercial Code — perfection, priority, and filing requirements
• 42 U.S.C. § 4012a (National Flood Insurance Act): https://www.law.cornell.edu/uscode/text/42/4012a
• ALTA Title Insurance Forms: https://www.alta.org/
• SAM.gov (System for Award Management): https://sam.gov/

This SBA Loan Closing Checklist is provided by ezel.ai for use by licensed attorneys, SBA lending professionals, and closing agents. Requirements may vary by lender, loan program, and transaction type. Always confirm specific requirements with your SBA lender and SBA counsel. This document does not constitute legal advice.